M/S TATA GLOBAL BEVERAGES LIMITED,KOLKATA vs. THE DCIT, CIRCLE-4(2), KOLKATA, KOLKATA

In the result, the appeals filed by the assessee for AY 2012-

Bench: Dr. Manish Borad & Sonjoy Sarma

Transfer Pricing Guidelines 2010 supports this view in para 7.13 where it is explained that where higher credit rating of Associated Enterprise is due to a guarantee by another group member, such association positively enhances the profit making potential of that Associated Enterprise. We, therefore, find ourselves in agreement with the contention of the Page 27 of 41 I.T.A

M/S. PHILIPS INDIA LIMITED,KOLKATA vs. D.C.I.T., CIRCLE - 11(1), KOLKATA

In the result, the appeal of the assessee is allowed

Bench: Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am M/S Philips India Limited Dcit, Circle 11(1) 3Rd Floor, Tower-A, Dlf Park, Aaykar Bhavan, P-7, 08 Block Af, Major Arterial Chowringhee Square, Road, New Town (Rajarhat), Vs. Kolkata-700069, Kolkata-700156, West Bengal West Bengal (Appellant) (Respondent) Pan No. Aabcp9487A Assessee By : Shri Ketan Ved, Ar Revenue By : Shri A. Kundu, Cit Dr Date Of Hearing: 07.03.2025 Date Of Pronouncement : 11.03.2025

transfer pricing adjustment stands deleted. Consequently, ground nos. 6 the assessee’s appeal stand allowed. 023. The issue raised in ground no.7, is against the disallowance of expenses of ₹7,50,50,000/- u/s 14A of the Act in relation to earning of exempt income. 024. The facts in brief are that during the year under consideration, the appellant

PCBL LIMITED,KOLKATA vs. A.C.I.T., CIRCLE - 11(1),, KOLKATA

In the result, all the appeals of the revenue are dismissed and the appeal filed by the assessee is partly allowed for statistical purposes

Bench: Shri Pradip Kumar Choubey&Shri Sanjay Awasthi]

Transfer Pricing Officer, case was referred to the TPO, consequent to the reference, the TPO forwarded the order u/s 92CA(3) of the Act and downward adjustment to the income of the assessee with respect to 80IA units is computed at Rs. 28,34,57,200/-. The AO after considering the order passed by the TPO and reply submitted

PRAMOD LAKRA,DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE -11(1), KOLKATA, KOLKATA vs. PHILIPS CARBON BLACK LTD , KOLKATA

In the result, all the appeals of the revenue are dismissed and the appeal filed by the assessee is partly allowed for statistical purposes

Bench: Shri Pradip Kumar Choubey&Shri Sanjay Awasthi]

Transfer Pricing Officer, case was referred to the TPO, consequent to the reference, the TPO forwarded the order u/s 92CA(3) of the Act and downward adjustment to the income of the assessee with respect to 80IA units is computed at Rs. 28,34,57,200/-. The AO after considering the order passed by the TPO and reply submitted

PRAMOD LAKRA,DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 11(1), KOLKATA, KOLKATA vs. PHILLIPS CARBON BLACK LTD., KOLKATA

In the result, all the appeals of the revenue are dismissed and the appeal filed by the assessee is partly allowed for statistical purposes

Bench: Shri Pradip Kumar Choubey&Shri Sanjay Awasthi]

Transfer Pricing Officer, case was referred to the TPO, consequent to the reference, the TPO forwarded the order u/s 92CA(3) of the Act and downward adjustment to the income of the assessee with respect to 80IA units is computed at Rs. 28,34,57,200/-. The AO after considering the order passed by the TPO and reply submitted

PRAMOD LAKRA, DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 11(1), KOLKATA, KOLKATA vs. PHILLIPS CARBON BLACK LTD, KOLKATA

In the result, all the appeals of the revenue are dismissed and the appeal filed by the assessee is partly allowed for statistical purposes

Bench: Shri Pradip Kumar Choubey&Shri Sanjay Awasthi]

Transfer Pricing Officer, case was referred to the TPO, consequent to the reference, the TPO forwarded the order u/s 92CA(3) of the Act and downward adjustment to the income of the assessee with respect to 80IA units is computed at Rs. 28,34,57,200/-. The AO after considering the order passed by the TPO and reply submitted

PRAMOD LAKRA, DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-11(1), KOLKATA, KOLKATA vs. PHILLIPS CARBON BLACK LTD, KOLKATA

In the result, all the appeals of the revenue are dismissed and the appeal filed by the assessee is partly allowed for statistical purposes

Bench: Shri Pradip Kumar Choubey&Shri Sanjay Awasthi]

Transfer Pricing Officer, case was referred to the TPO, consequent to the reference, the TPO forwarded the order u/s 92CA(3) of the Act and downward adjustment to the income of the assessee with respect to 80IA units is computed at Rs. 28,34,57,200/-. The AO after considering the order passed by the TPO and reply submitted

DCIT, CIR-5(1), , KOLKATA vs. M/S COAL INDIA LTD., KOLKATA

iv) Hindusthan paper Corporation No.47/Kol/2012. Ltd. in ITA\nNO.47/KOL/2012\nThe aforesaid judgements will not support the case of the assessee\nas the same are rendered in the different facts altogether. In the\naforesaid decisions, the ratio was that only those expenditures which\nhas nexus to the exempt income are to be disallowed. However in the\npresent case the nexus between

DCIT, CIRCLE - 5(1), KOLKATA, KOLKATA vs. M/S. COAL INDIA LIMITED , KOLKATA

iv) Hindusthan paper Corporation No.47/Kol/2012. Ltd. in ITA NO.47/KOL/2012 The aforesaid judgements will not support the case of the assessee as the same are rendered in the different facts altogether. In the aforesaid decisions, the ratio was that only those expenditures which has nexus to the exempt income are to be disallowed. However in the present case the nexus between

DCIT, CIRCLE - 5(1), KOLKATA, KOLKATA vs. M/S. COAL INDIA LIMITED , KOLKATA

In the result, the appeals filed by the assessee in ITA Nos

iv) Hindusthan paper Corporation No.47/Kol/2012. Ltd. in ITA\nNO.47/KOL/2012\nThe aforesaid judgements will not support the case of the assessee\nas the same are rendered in the different facts altogether. In the\naforesaid decisions, the ratio was that only those expenditures which\nhas nexus to the exempt income are to be disallowed. However in the\npresent case the nexus between

DCIT, CIR-5(1), , KOLKATA vs. M/S COAL INDIA LTD., KOLKATA

iv) Hindusthan paper Corporation No.47/Kol/2012. Ltd. in ITA\nNO.47/KOL/2012\nThe aforesaid judgements will not support the case of the assessee\nas the same are rendered in the different facts altogether. In the\naforesaid decisions, the ratio was that only those expenditures which\nhas nexus to the exempt income are to be disallowed. However in the\npresent case the nexus between

M/S. COAL INDIA LIMITED ,KOLKATA vs. DCIT, CIRCLE - 5(1), KOLKATA, KOLKATA

iv) Hindusthan paper Corporation No.47/Kol/2012. Ltd. in ITA\nNO.47/KOL/2012\nThe aforesaid judgements will not support the case of the assessee\nas the same are rendered in the different facts altogether. In the\naforesaid decisions, the ratio was that only those expenditures which\nhas nexus to the exempt income are to be disallowed. However in the\npresent case the nexus between

COAL INDIA LIMITED ,KOLKATA vs. DCIT, CIRCLE - 5(1), KOLKATA, KOLKATA

iv) Hindusthan paper Corporation No.47/Kol/2012. Ltd. in ITA\nNO.47/KOL/2012\nThe aforesaid judgements will not support the case of the assessee\nas the same are rendered in the different facts altogether. In the\naforesaid decisions, the ratio was that only those expenditures which\nhas nexus to the exempt income are to be disallowed. However in the\npresent case the nexus between

M/S COAL INDIA LTD.,KOLKATA vs. DCIT, CIR-5(1), , KOLKATA

iv) Hindusthan paper Corporation No.47/Kol/2012. Ltd. in ITA\nNO.47/KOL/2012\nThe aforesaid judgements will not support the case of the assessee\nas the same are rendered in the different facts altogether. In the\naforesaid decisions, the ratio was that only those expenditures which\nhas nexus to the exempt income are to be disallowed. However in the\npresent case the nexus between